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Privacy Policy & Notice

We are Goatley Hirst Ltd with registered number 12267413 and address Kingfisher House, 21-23 Elmfield Rd, Bromley BR1 1LT. Our Data Protection Lead can be contacted at sales@goatleyhirst.com. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the UK Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 ("Data Protection Legislation").

The terms "Personal Data", "Special Categories of Personal Data", "Personal Data Breach", "Data Protection Officer", "Data Controller", "Data Processor", "Data Subject" and "process" (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. "Data Protection Lead" is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.

01

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

  • /The right to be informed of how your Personal Data is used (through this notice);
  • /The right to access any personal data held about you;
  • /The right to withdraw consent at any time, by emailing sales@goatleyhirst.com;
  • /The right to rectify any inaccurate or incomplete personal data held about you;
  • /The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
  • /The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
  • /The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by contacting sales@goatleyhirst.com with the subject line: "Subject Access Request". When you submit a 'subject access request', you will need to provide confirmation of your identity by including a photocopy of your driver's license or passport. This service is provided free of charge and our response will be made within thirty (30) days, unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section 'Who can you complain to?'.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at sales@goatleyhirst.com.

02

Who is the Data Controller?

  • /If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
  • /If we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
  • /If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
  • /If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
  • /If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, Goatley Hirst Ltd, at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below 'Third Party Interests'.
  • /If we have received your personal data as part of a business to business relationship, the Data Controller is your employer.
03

What are the lawful bases for processing personal data?

Under Data Protection Legislation, there must be a 'lawful basis' for the use of personal data. The lawful bases are:

  • /a) 'your consent';
  • /b) 'performance of a contract';
  • /c) 'compliance with a legal obligation';
  • /d) 'protection of your, or anothers' vital interests';
  • /e) 'public interest/official authority'; and
  • /f) 'our legitimate interests'.
04

What are our 'legitimate interests'?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.

05

About our processing of your data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • /Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • /Contact Data includes billing address, delivery address, email address and telephone numbers.
  • /Financial Data includes bank account and payment card details.
  • /Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • /Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • /Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • /Usage Data includes information about how you use our website, including your log-in data, and the resources that you access and use.
  • /Marketing Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
06

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • /Where we need to perform the contract we are about to enter into or have entered into with you.
  • /Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • /Where we need to comply with a legal obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you by email or equivalent. You can withdraw consent at any time by contacting sales@goatleyhirst.com.

07

Change of purpose

We will only use your personal data for the purposes for which we collected it, as described above. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

08

Data sharing

We may share your personal data with third parties, including third-party service providers and other entities within the Goatley Hirst Ltd group, in the following circumstances:

  • /Service providers acting as data processors who provide IT and system administration services, marketing services, and other services to us.
  • /Third parties to whom we may transfer, or entrust with, your personal data as part of a corporate transaction, or a transfer of some or all of our business or assets, or in connection with any restructuring or reorganisation.
  • /Where we are required to share your personal data by law, court order, or to comply with regulatory obligations.
09

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10

Security of your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, disclosed, or destroyed. Access to your personal data is limited to those who have a genuine business need to access it.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11

Your rights in more detail

You have the right to request access to, rectification, erasure, or restriction of processing of your personal data, and to object to processing. You also have the right to data portability. To exercise any of these rights, please contact our Data Protection Lead at sales@goatleyhirst.com.

You may also have the right to withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw consent.

12

Who can you complain to?

If you are not happy with the way in which we have handled your personal data, or if you have any questions about this privacy notice, please contact our Data Protection Lead at sales@goatleyhirst.com in the first instance.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at www.ico.org.uk.

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